Purchasing Card Policy

The Columbia University Purchasing Card (P-Card) is the preferred payment method for most business related, non-travel, small dollar purchases (under $2,500 per transaction) of goods and limited services by Columbia University’s schools and departments. The use of a purchasing card significantly reduces the time spent purchasing and paying for small-dollar, high-volume transactions while maintaining adequate controls.


A P-Card is a credit card that authorized University personnel may use to purchase goods and limited services for use by the University.  P-Cards are issued to individuals who meet the appropriate requirements and can only be used by the individual named on the card. Contractors, consultants and students are not eligible to obtain a P-Card.  Columbia University is liable to the financial institution that issues the P-Cards for all valid transactions and pays the financial institution directly.  P-Card transactions bring greater efficiency to the purchasing process because transactions can be made without a purchase order and payment is streamlined.

The University has chosen a Purchasing Card program offered through a card-issuing Financial Services Provider (“Card Issuer”). This program is governed by the terms and conditions of a Master Agreement between Columbia University and the Card Issuer.  The Card Issuer provides a web-based system to manage the Program.  





Accounts Payable administers the P-Card Program, and is responsible for supporting schools and departments in utilizing the Program to execute and pay for small purchases in an effective, efficient and appropriately controlled manner.   Accounts Payable is solely authorized to make any modifications or exceptions to the program and to perform administrator tasks such as setting-up users, changing card controls, etc., in the card management system and ARC.  Accounts Payable maintains all forms and policies and procedures directly associated with the program.  Accounts Payable is responsible for developing, updating and administering all audit and disciplinary policies related to the P-Card program.  Procurement Services, Accounts Payable will approve payment of the monthly card charges based on the bill from the Card Issuer and the information in the card management system and ARC.



Authorized University personnel who make frequent, low-dollar purchases for University business and are issued a P-Card will hold the role of Cardholder.  A Cardholder makes purchases, has a legitimate business purpose for all P-Card transactions, regularly reviews his or her transactions, allocates transactions to the correct accounting codes, provides a business purpose when necessary, and maintains their P-Card receipts for review and audit purposes. As a Cardholder, one is fully entrusted as a purchaser of goods for Columbia University. Purchases must always be made in the best interest of the University.



A Reconciler is the person to whom the Cardholder has delegated all the functions associated with post-purchase processing in ARC including account allocation and providing a business purpose when required.  The Reconciler role can be given to either the Cardholder or assigned to a proxy to reconcile on the Cardholder’s behalf. A Reconciler cannot make purchases using the card belonging to the Cardholder for whom they reconcile. The Cardholder is responsible for all actions taken by the Reconciler on his or her behalf.           



A Reviewer reviews P-Card transactions for a Cardholder(s).  This role is view only and will not have the ability to either reconcile or approve transactions.  



An Approver is the person who approves purchases that have been made by the Cardholder(s) to which he or she is assigned.   By approving each transaction, the Approver exercises critical control by ensuring authorized and appropriate P-Card use and correct allocation of expenses in accordance with Accounts Payable, Purchasing and other related University policies. An Approver must have sufficient knowledge and understanding of the Cardholder’s P-Card activity to competently perform the approval process.   Approvers should also review receipts where appropriate to ensure compliance with this and other University policies.  An Approver must have Departmental Authorization Function (DAF) voucher approval authority of $2,500 or greater.


No Cardholder may approve his or her own purchases/transactions nor may he or she direct someone else to approve transactions in a manner that would violate policy, i.e., without reviewing the transactions in detail, etc.  As a general rule, the Approver should not report to the Cardholder whose transactions he or she is reviewing. Approving transactions without review is not only a violation of this policy but is also a critical financial control failure.



A Departmental P-Card Administrator is responsible for ensuring that his or her school or department follows the policies and procedures for the P-Card program.  A Departmental P-Card Administrator is also the primary liaison between Accounts Payable and the P-Card program participants in his or her department or school.  He or she manages and approves the documentation related to new card applications and changes in cardholder information (name, increase or decrease in limits, etc.) or employment status.  


The Departmental P-Card Administrator should conduct a regular review of transactions for compliance with P-Card policies and procedures. The Departmental P-Card Administrator is also responsible for working with Accounts Payable and/or their senior management to administer all disciplinary policies for his or her P-Card participants, including informing the Cardholder’s immediate supervisor of any complaints or infractions.  The Departmental P-Card Administrator can request that a card be terminated by the P-Card staff at any time. If a Departmental P-Card Administrator lacks the appropriate level of knowledge to properly review specialized P-Card transactions, then additional assistance should be obtained as needed.



The Senior Financial Administrator of a school or department is responsible for overall monitoring of their school’s or department’s Purchasing Card program to ensure compliance with all policies and procedures and is responsible for administering the disciplinary policies for their participants.  


Please note:  It is possible for one person to hold more than one role; however, Cardholders cannot approve their own transactions.



Authorization to hold a P-Card and approve P-Card transactions is governed by the University’s internal DAF policy via the DAF system. The department’s DAF has to approve the Finance Services Security Application, which will designate the P-Card roles assigned to a user.   Please review the DAF policy on the Administrative Policy Library.



While the P-Card may be used to make purchases and thereby incur related charges on grants and contracts, special efforts are required to insure that the charges themselves are permissible in accordance with the terms of those grants and contracts. Please review related policies and procedures on the Sponsored Project Finance section of the Finance Gateway. 



Cardholders should utilize the lowest price based on requirements, quality, and availability to obtain the maximum value for each dollar expended.



All purchases utilizing a University P-Card should be in the name of the University, and not on a personal account. All deliveries for P-Card purchases should be to Columbia University locations. If an exception to this requirement is necessary, it should be disclosed to the Approver, along with an appropriate justification. This disclosure should be retained with the supporting documentation for the P-Card purchase.



Periodic reviews of each Cardholder’s records (i.e., Cardholder receipts and other supporting documents) will be performed by Internal Audit, Procurement Services, the University’s financial auditors or others who perform audits on the University’s behalf as well as external auditors and federal, regulatory and other granting agencies. Intentional or fraudulent misuse of the P-Card may result in disciplinary action up to and including dismissal from the University.

All transactions must be ‘Verified’ by the cardholder/reconciler.  All transactions must then be ‘Approved’ by a designated Approver.  No transaction can be ‘Verified’ and ‘Approved’ by the same individual. Only Verified transactions can be Approved.  The transaction status must not be changed from Staged to Approved without the knowledge and consent of the cardholder/Reconciler.  



While the P-Card may be used to purchase most goods and limited services, some items are not permitted to be purchased when using a P-Card because the commodities/items require additional oversight or control in advance of the purchase.  Such items include radioactive materials, lasers, alcohol, bio hazardous materials, controlled substances, etc.

The P-Card also cannot be used for the purchase of goods and services that require governmental licenses or permissions or that are controlled under U.S. export controls.   Export controls refer to items (A) identified as “defense articles” under the U.S. International Traffic in Arms Regulations (“ITAR”) of the Department of State or (B) assigned an Export Classification Number (“ECCN”) entry on the U.S. Commerce Control List of the Export Administration Regulations (“EAR”).    Examples of export-controlled items include certain navigation systems, protective equipment, underwater sound equipment, lasers, encryption software, and night vision goggles.   For assistance in determining whether an item is export-controlled, please coordinate with your departmental administration, who will in turn seek advice from central administration resources as needed.

Please refer to Appendix A to see additional examples of items that are not approved for purchase using the P-Card.  This list is not all-inclusive; if there are any questions about whether or not the P-Card can be used for a purchase, please contact the P-Card team at [email protected] or the Finance Service Center at 212-854-2122.



Misuse of the P-Card and violation of the P-Card policy will result in disciplinary action (see appendix B: Infractions/Corrective Actions/Suspensions). Evidence of intentional or fraudulent violations of the P-Card policy will be submitted to the Internal Audit Fraud investigation unit for further review. Examples of misuse and policy violations include, but are not limited to: 


  • Purchase of items for personal use
  • Purchase of restricted commodities 
  • Splitting of purchase or service cost over multiple card transactions in order to circumvent the single transaction limit
  • Use of the card by anyone or any department other than the authorized cardholder

 Administrative Violations

  • Failure to obtain and maintain supporting documentation for all card transactions
  • Failure of Cardholder and/or Approver to sign off on transactions by hard close deadline
  • Signing off on transactions without proper review
  • Lack of timely and proper reconciliation of posted transactions
  • Allocation of charges to sponsored project accounts in a manner that is inconsistent with federal or other guidelines
  • Approval of transactions that violate University policies

Intentional or Fraudulent Misuse

  • Falsely claiming personal purchases as legitimate University expenses.  This includes false comments in ARC. 
  • Submitting false or altered documents to justify P-Card transactions
  • Knowingly using the P-Card for expenses that do not adhere to department guidelines
  • Utilizing any vendor where an undisclosed conflict of interest is present


If any P-Card participant violates the P-Card policies and procedures, the participant may be subject to sanctions including suspension of the card program privileges, card cancellation, and other disciplinary action as deemed appropriate by the University.  Intentional or fraudulent misuse can result in disciplinary action up to and including termination from the University and potential civil and/or criminal prosecution (see appendix B: Infractions/Corrective Actions/Suspensions).


Reporting Misuse

Any known or suspected misuse of a P-Card, or pressure to violate any part of this policy, can be reported to P-Card staff, the Columbia University IA Fraud Investigation unit, or the Columbia University compliance hotline. The compliance hotline is managed by a third party, and any complaints or issues can be communicated anonymously:

Compliance Hotline Number: 1-866-627-3768





  • To obtain a P-Card, the applicant must first obtain the P-Card cardholder role within the Finance Security Service Administration(FSSA) form.
  • The single transaction limit which is assigned to a Cardholder must be within the approving manager’s DAF authority.
  • Every participant must complete the appropriate P-Card training and Policy assessment/acknowledgment before the card application and ARC access will be available for use.
  • Cardholders will receive their P-Card once the application has been successfully approved by the DPAD, Policy training completed and assessment taken and successfully completed.   


The P-Card and all account information should be kept in a secure place, and the card number should not be posted, emailed or visible in any place that is accessible by others. Each Cardholder is directly responsible for the physical security of their card and account information.



If the P-Card is lost or stolen, the Cardholder must immediately notify the following:

  • Card Issuer by calling 1-888-449-2273 
  • Departmental P-Card Administrator
  • P-Card team ([email protected]) or the Finance Service Center at 212-854-2122


The account will automatically be closed and every effort will be made to have a new account opened within one week after notification.  The University is liable for all unauthorized use of the card until the Card Issuer is notified.  All charges associated with a card will be allocated to the department to which the Cardholder was assigned when the card was issued.



P-Cards are the property of Columbia University and the Card Issuer and can be terminated at any time by either the University or the Card Issuer.  Cardholder or Approver security access must be removed through the ARC Security process as well as notification sent to the P-Card Administration staff.  University personnel who become aware of personal misuse should notify the P-Card team immediately.  P-Cards may be suspended or deactivated for the following reasons:


Inactivity - Cardholders that have not used their P-Card for a period of six consecutive months may be subject to card suspension and/or cancellation.  Upon suspension, if the Cardholder does not request that the P-Card be reactivated within 6 months of the suspension date, the P-Card team may cancel the P-Card.


P-Card Misuse 


Cardholder moves to a new department in the University - If a Cardholder transfers to another department, the P-Card must be turned over to the Departmental P-Card Administrator (DPAD) and the account will be closed.  The department will be held responsible for all charges made on the card until it has been canceled and Accounts Payable has been notified.  If a Cardholder needs a P-Card in his or her new department, he or she should follow the procedures for establishing a new Cardholder. 

Cardholder leaves the University - When a Cardholder leaves the University, the P-Card must be turned over to the Departmental P-Card Administrator (DPAD) and the account permanently closed.  If a Cardholder believes a card has been suspended or cancelled in error, he or she should contact the DPAD immediately.


Cardholders are strongly encouraged to use University-wide Purchasing Agreements (UwPAs) for their P-Card purchases.  For the most current list of UwPAs please visit the Procurement Services/Purchasing section on the Finance Gateway.  Accounts Payable will review P-Card transactions on a regular basis to analyze preferred vendor utilization and will review any resulting opportunities with the Departmental P-Card Administrator.  Accounts Payable will also work with the Card Issuer and VISA to encourage vendors who do not accept credit cards to add cards as a payment method. 

All purchases must be made in accordance with applicable laws and regulations, including, but not limited to Columbia University’s policies and procedures, which can be found on the Finance Gateway.

Purchases can only be made by the person to whom the card is issued.  Any other use is a violation of University policy, and the person to whom the card is issued as well as the unauthorized user may be subject to disciplinary action.  

The following are some common examples of approved items for purchase using the P-Card.  


  • Books
  • Minor computer equipment, software, and supplies 
  • Lab supplies and minor equipment 
  • Registrations for conferences and seminars
  • Subscriptions and memberships
  • Professional membership and license fees
  • Supplies and materials
  • Postage
  • Newspaper, journal, on-line advertising fees


Non-Consultant Services

The P-Card may also be used to procure some types of non-consultant services.  In general, non-consultant services may be purchased via the P-Card provided they are governed by a University-wide Purchasing Agreement (UwPA), or where they do not require contractual or purchase order terms and conditions binding the University or the vendor. (Please note: most repairs and services not governed by a

UwPA require a PO so please contact the P-Card team at [email protected] or the Finance Service Center at 212-854-2122 if you are uncertain if the P-Card can be used for a purchase.) Schools and departments are encouraged to charge the following services where appropriate:

  • Couriers
  • Overnight air and ground delivery (UwPA vendors preferred – excluding items that require HIPPA compliance) 
  • Medical transcription (UwPA vendors only)
  • Medical Answering services (UwPA vendors only)
  • Cell phone and pager charges individual or group plans  (UwPA vendors preferred)
  • Water and Coffee deliveries (UwPA preferred)
  • Record Storage (UwPA vendors only)
  • Shredding Services (UwPA vendors only)
  • Uniform Cleaning and Rental (UwPA vendors only)
  • Moving & Storage services (UwPA vendors only)
  • Other metered services 
  • Printing purchases
  • Promotional Items (Purchasing CU Approved vendors only)  -


Please note, all invoices and/or bills must identify Columbia University as the “Bill-To” and the bill-to and shipping address must be a Columbia University address.


This list is not all-inclusive; if there are any questions about whether or not the P-Card can be used for a purchase, please visit the P-Card section of the Finance Gateway or the Purchasing Guide for a more inclusive list of acceptable uses.


While schools and departments are encouraged to use the P-Card for most small purchases of goods, as well as appropriate services, some purchases may not be made via P-Card because they require additional oversight or control in advance of purchase. Please refer to Appendix A to see examples of items that are not approved for purchase using the P-Card.  This list is not all-inclusive; if there are any questions about whether or not the P-Card can be used for a purchase, please contact the P-Card staff at [email protected] or the Finance Service Center at 212-854-2122.



The P-Card may be used (with DPAD approval) to make small purchases of food from local food merchants for consumption at a work-related meeting or class at a University-owned or leased property. Such purchases may not include catering services that involve execution of a contract by the University and/or provision of labor by a vendor at an event.  The P-Card may not be used to purchase food while traveling on University business or for meals eaten in a restaurant or eating establishment.  For all food purchases made under this policy the following information must be entered into ARC when reconciling transactions:


  • Purpose of the event or meeting
  • Type of meal (breakfast, lunch or dinner)
  • Date and location of the event or meeting
  • Names of attendees (or a number if there are more than 10 names)
  • Average cost per person 


All such purchases should be consistent with the University’s policies with respect to cost per person and any other related provisions. Please refer to the Travel & Business Expense policy for additional information.  In addition, Reconcilers are required to scan and attach all receipts to P-Card food transactions in ARC.



The P-Card has both a “Single Transaction Limit” and a “Monthly Credit Limit” which is determined by the Cardholder’s Departmental P-Card Administrator (DPAD).  The Single Transaction Limit is set at $2,500 or lower, based on the amount the Cardholder is authorized to spend on each P-Card transaction. The single transaction limit cannot exceed $2,500. The Monthly Credit Limit is set to the total dollar amount that the Cardholder will spend on business related items within a month.  With the exception of increasing the Single Transaction Limit above $2,500, these limits may be changed where appropriate and only when approved by the DPAD.  


It is explicitly prohibited for a Cardholder to “split” the purchase of merchandise in order to circumvent the “Single Transaction Limit.”  Intentionally doing so may result in the immediate cancellation of the P- Card.  A transaction includes the purchase price, sales tax (if applicable), and freight and/or handling.  Any transaction that exceeds the Single Transaction Limit will be rejected by the merchant.  


All transactions during the billing period in excess of the Monthly Credit Limit before the end of the billing cycling will be rejected by the merchant.  In the event this occurs and there was an exceptional and/or urgent circumstance, the Cardholder or the Departmental Program Administrator may call the P-Card staff to review any available options.



Cardholders should remind vendors at the time of purchase that according to the tax laws in some states, the University is exempt from sales tax.  For a list of states that honor the University’s tax-exempt status please contact the Finance Service Center at 212-854-2122 or online.  The University’s tax-exempt number is printed on the P-Card and Cardholders should keep a copy of the tax-exempt form with them to present to the vendor at the time of purchase.  To request a copy of the University’s tax-exempt form, please contact the Finance Service Center at 212-854-2122 or online.  If a Cardholder is charged sales tax for a P-Card purchase that should be tax-exempt, the Cardholder should contact the vendor directly and request a credit.  



It is the Cardholder and Approver’s responsibility to review all transactions for accuracy, appropriate business purpose, reconcile with invoices/receipts/records, assign proper accounting, and sign-off on all P-Card transactions as quickly as possible after the purchase.  It is strongly recommended that this be completed once a week, but must be completed by the hard close.  The Cardholder and Approver should review each transaction to ensure compliance with the following items:



  • All purchases must have a valid University business purpose



  • Purchases meet all grant or regulatory requirements (if the purchase is allocated to a grant or federally funded account)


  • All required receipts are accounted for and are maintained in accordance with this policy



It is the Cardholder’s responsibility to maintain itemized receipts that document the nature and cost of all purchases made with a P-Card in accordance with University Finance retention policies.



An itemized receipt generally includes the following information:   

  • Purchase date [ex. 06/15/06];
  • Vendor name [ex. Poland Spring Water];
  • Item(s) description [ex. Case of 24 bottles of water];
  • Quantity [ex. 2];
  • Unit price [ex. $6.98]; and 
  • Total charge [ex. $13.96]


If this information is not on the receipt, the Cardholder should write that information on it.  A receipt can be in the form of a cash register receipt, a copy of an order form (i.e., for subscriptions or conference registrations), or a web receipt or email acknowledgement from the vendor.  The receipt should provide sufficient detail to support the business purpose of the purchase. Please note, any transactions processed with a 3rd party vendor (i.e., PayPal, Square, etc.) requires an itemized receipt for audit purposes.

 Occasionally, the Cardholder may lose a receipt.  The Cardholder should document the details about the purchase including date, vendor name, item(s) description, quantity, unit price and total charge. For convenience, the P-Card Department has provided a “missing receipt” worksheet that may be completed.



If goods purchased with the P-Card need to be returned, the Cardholder must contact the vendor directly and request a credit to their P-Card account.  This policy prohibits any other type of credit including cash.



Cardholders must attempt to resolve all disputes directly with the vendor.  If the Cardholder cannot resolve the issue with the vendor, the Cardholder should dispute the transaction with the card issuer.   Once a good faith effort has been made to resolve a problem with a vendor, the transaction can be disputed through the Card Issuer.   Sales tax may not be disputed and must always be addressed directly with the vendor.   


In accordance with our agreement with the Card Issuer, a dispute must be initiated no later than 60 days after the date of the transaction.  Failure to do so will result in the dispute being rejected and the University and corresponding department will be responsible for the charges.


The following is a list of items that cannot be purchased on the P-Card. This list is not all-inclusive; if there are any questions about whether or not the P-Card can be used for a purchase, please contact the P-Card staff at [email protected] or contact the Finance Service Center at 212-854-2122.

  • Personal items
  • Items requiring governmental licenses or permissions or that are controlled under U.S. export controls
  • Split transactions*
  • Alcohol (beverage or otherwise)
  • Travel (airline, car rental, lodging, taxi, car services, shuttle buses, etc.)
  • Entertainment (movie tickets, sporting event tickets, etc.)
  • MetroCards, purchased for any reason
  • Food is eaten off-campus for any reason (meals, receptions, etc.)
  • Food purchased for on-campus meetings where the P-Card was not approved for this type of use
  • Flowers, greeting cards, candy, fruit baskets
  • Purchases from Edible Arrangements
  • Gifts/prizes/awards of any kind
  • Gift cards and gift certificates of any kind for any reason
  • Any promotional items with University Logo or trademark or any branded product not purchased thru an approved Licensed Vendor.
  • Fines of any kind
  • Purchases using personal PayPal accounts
  • Maintenance and Service agreements
  • On-site Equipment repairs
  • Cash advances, cashback on purchases, cash refunds on returns
  • Controlled substances
  • Live animals
  • Radioactive materials and specialty gases
  • Contracted services from an individual or 1099 vendors
  • Honorariums
  • Furniture
  • Fuel
  • Leases /Rentals
  • Insurance
  • Employee relocation and relocation-related expenses
  • Catering
  • Parking
  • Charitable Contributions
  • Fees for Foreign Nationals of any kind (Visa’s etc.)
  • Online auctions (i.e. eBay, Craigslist)
  • Groupon
  • Courier service for  any items which require HIPPA compliance
  • Cloud Hosting, Cloud Storage and File Sharing services
  • Non-UWPA Vendor Purchases for Shredding Services, Moving and Records storage; and Uniform Cleaning and/or Rental

*Cardholders are not permitted to divide a single invoice or purchase into multiple transactions to avoid their single transaction limit. An example of a split transaction would be the following scenario:  Total purchase is $3,000 and the Cardholder has a single transaction limit of $2,500.  The Cardholder has the vendor split the order into amounts of $1000, $1000 and $1000 so the original transaction is not declined. Deliberately instructing a vendor to restructure a transaction for the purpose of avoiding this restriction is also prohibited and can result in disciplinary action up to and including termination from the university.


    All P-Card transaction are audited on a regular basis.  The audit has been established to prevent risk and financial loss to the University and the assist schools/departments with compliance with the University P-Card Policy.  

    Areas of Review and Audit 

    Cardholder/Reconciler Sign-off  

    Cardholders/Reconcilers must sign-off on all P-Card transactions for the billing cycle by the Hard Close deadline. The Hard Close includes all P-Card transactions with an ARC Statement Billing Date of the 22nd of the month. 

    Failure to sign-off by the Hard Close will result in the following corrective action:

    Approver Sign-off  

    Approvers must sign-off on all P-Card transactions for the billing period by the Hard Close deadline. The Hard Close includes all P-Card transactions with an ARC Statement Billing Date of the 22nd of the month.   

    Failure to sign-off by the Hard Close will result in the following corrective action:

    Business Purpose for Food Transactions 

    Cardholders/Reconcilers are required to add a complete business purpose for all food transactions made with a restaurant or grocery store for food that will be consumed at an on-campus meeting. The complete business purpose must include: 

    • date of the meeting, 
    • location of the meeting, 
    • type of meal, 
    • names of individuals at the meeting (if attendance is over 10 the number is sufficient), 
    • the business purpose for the meeting
    • scan/upload a copy of the itemized receipt into ARC.   

    Failure to provide any and/or all details necessary before the Hard Close will result in the following corrective action:


    Misuse of the P-Card and violation of the P-Card policy will result in disciplinary action. Evidence of intentional or fraudulent violations of the P-card policy will be submitted to the Internal Audit Fraud investigation unit for further review.

    Use of the P-Card for a Restricted Purchase 

    A restricted purchase is when a Cardholder makes a purchase that is prohibited by policy with their P-Card. This includes purchases of travel, entertainment, food eaten off campus, gift certificates of any kind, and fines.  

    Cardholders who make restricted purchases will be subject to the following corrective action:

    Use of the P-Card for a Split Transaction 

    Cardholders are not permitted to divide a purchase into multiple transactions to avoid their single transaction limit. An example of a split transaction would be the following scenario:  Total purchase is $3,000 and the Cardholder has a single transaction limit of $2,500.  The Cardholder has the vendor split the order into amounts of $1,000, $1,000 and $1,000.

    Cardholders who split their P-Card transactions will be subject to the following corrective actions:  

    Use of the P Card for a Personal Purchase

    Personal Purchases are not permitted on the P-Card.

    Cardholders who make personal purchases will be subject to the following corrective action:

    All participants are encouraged to review the P-Card Policy to acquaint themselves with their roles and responsibilities in the P-Card program and to ensure regular compliance. 

    If you have any questions regarding this process please contact the P-Card staff at [email protected].